Finding 1123690 (2024-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 351580
Organization: Johnson C. Smith University (NC)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The University inaccurately reported key information for federal student aid programs, leading to non-compliance with COD reporting requirements.
  • Impacted Requirements: Errors were found in origination and disbursement records, including incorrect cost of attendance and late disbursement submissions.
  • Recommended Follow-Up: Enhance internal controls and implement formal policies to ensure accurate and timely reporting; establish a monthly reconciliation process and provide regular staff training starting May 2025.

Finding Text

Federal Program Information: Federal Pell Grant Program (ALN: 84.063) and Federal Direct Student Loans (ALN: 84.268) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): L. Reporting – Financial Reporting – Federal regulations require the University to submit origination and disbursement records for students to the Common Origination and Disbursement System (“COD”). Items considered key in student origination records, if applicable, are: award amount, enrollment date, verification status code (when the applicate is selected for verification), transaction number, cost of attendance, and the “Academic Start Date” and “Academic End Date”. Institutions must also submit disbursement records to the COD for students no earlier than 7 calendar days prior to the disbursement date, and no later than 15 calendar days after the institution makes a disbursement. Key items to test on disbursement records are disbursement date and amount. Condition: For certain students identified through our testing, errors were identified in key items reported to the COD in student origination and disbursement records. Additionally, the University failed to report disbursement records for certain students within the required timeframe. Cause: Insufficient administrative oversight and internal controls with respect to accurate reporting of federal award information. Effect or Potential Effect: The University was not in compliance with COD reporting requirements. Questioned Costs: None. Context: We noted the following exceptions during our testing: • For 14 of 25 students selected for origination record testing, the student’s cost of attendance was inaccurately reported within COD. • For 1 of 25 students selected for origination record testing, the “Academic End Date” was inaccurately reported within COD. • For 1 of 25 students selected for disbursement record testing, the University did not submit required disbursement information within the required timeframe. • For 7 of 25 students selected for disbursement record testing, the award disbursement date was inaccurately reported within COD. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the University enhance its internal controls and implement formal policies and procedures over the applicable compliance requirements to ensure origination and disbursement records are reported accurately and timely to COD for Direct Loan and Pell Grant recipients, in accordance with federal regulations. Views of Responsible Officials: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS systems contributed to erroneous COA budgets. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition from the use of PowerFaids to Ellucian Colleague for financial aid management. Resulting from the work of FAS, the University will institute a systematic monthly reconciliation process to ensure consistency across all systems (COD, PowerFAIDS, Jenzabar and Colleague). This includes matching COA and disbursement records to ensure accuracy. To optimize workflow, we will establish a comprehensive calendar of disbursement and reporting deadlines, with routine internal audits every 30 days, starting April 2025. This measure will enforce accountability and timeliness in reporting. We will enhance integration between financial systems (Jenzabar and PowerFAIDS) to prevent data mismatches and streamline the reporting process. In addition, we will leverage our partnership with FAS to conduct regular training sessions for staff across the Financial Aid, Registrar, and Finance Offices to ensure everyone is aware of compliance requirements and system functionalities. These training sessions will start May 2025.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Period of Performance Reporting

Other Findings in this Audit

  • 547245 2024-001
    Significant Deficiency
  • 547246 2024-001
    Significant Deficiency
  • 547247 2024-001
    Significant Deficiency
  • 547248 2024-002
    Significant Deficiency
  • 547249 2024-002
    Significant Deficiency
  • 547250 2024-003
    Significant Deficiency
  • 547251 2024-003
    Significant Deficiency
  • 547252 2024-003
    Significant Deficiency
  • 547253 2024-003
    Significant Deficiency
  • 547254 2024-004
    Significant Deficiency
  • 547255 2024-005
    Significant Deficiency
  • 547256 2024-005
    Significant Deficiency
  • 547257 2024-005
    Significant Deficiency
  • 547258 2024-005
    Significant Deficiency
  • 547259 2024-006
    Significant Deficiency
  • 547260 2024-006
    Significant Deficiency
  • 547261 2024-007
    Significant Deficiency
  • 547262 2024-007
    Significant Deficiency
  • 547263 2024-007
    Significant Deficiency
  • 547264 2024-008
    Material Weakness Repeat
  • 547265 2024-008
    Material Weakness Repeat
  • 547266 2024-008
    Material Weakness Repeat
  • 547267 2024-008
    Material Weakness Repeat
  • 547268 2024-008
    Material Weakness Repeat
  • 547269 2024-008
    Material Weakness Repeat
  • 547270 2024-009
    Significant Deficiency Repeat
  • 547271 2024-009
    Significant Deficiency Repeat
  • 547272 2024-010
    Significant Deficiency Repeat
  • 547273 2024-010
    Significant Deficiency Repeat
  • 547274 2024-010
    Significant Deficiency Repeat
  • 547275 2024-011
    Material Weakness Repeat
  • 547276 2024-011
    Material Weakness Repeat
  • 547277 2024-012
    Significant Deficiency Repeat
  • 547278 2024-012
    Significant Deficiency Repeat
  • 1123687 2024-001
    Significant Deficiency
  • 1123688 2024-001
    Significant Deficiency
  • 1123689 2024-001
    Significant Deficiency
  • 1123691 2024-002
    Significant Deficiency
  • 1123692 2024-003
    Significant Deficiency
  • 1123693 2024-003
    Significant Deficiency
  • 1123694 2024-003
    Significant Deficiency
  • 1123695 2024-003
    Significant Deficiency
  • 1123696 2024-004
    Significant Deficiency
  • 1123697 2024-005
    Significant Deficiency
  • 1123698 2024-005
    Significant Deficiency
  • 1123699 2024-005
    Significant Deficiency
  • 1123700 2024-005
    Significant Deficiency
  • 1123701 2024-006
    Significant Deficiency
  • 1123702 2024-006
    Significant Deficiency
  • 1123703 2024-007
    Significant Deficiency
  • 1123704 2024-007
    Significant Deficiency
  • 1123705 2024-007
    Significant Deficiency
  • 1123706 2024-008
    Material Weakness Repeat
  • 1123707 2024-008
    Material Weakness Repeat
  • 1123708 2024-008
    Material Weakness Repeat
  • 1123709 2024-008
    Material Weakness Repeat
  • 1123710 2024-008
    Material Weakness Repeat
  • 1123711 2024-008
    Material Weakness Repeat
  • 1123712 2024-009
    Significant Deficiency Repeat
  • 1123713 2024-009
    Significant Deficiency Repeat
  • 1123714 2024-010
    Significant Deficiency Repeat
  • 1123715 2024-010
    Significant Deficiency Repeat
  • 1123716 2024-010
    Significant Deficiency Repeat
  • 1123717 2024-011
    Material Weakness Repeat
  • 1123718 2024-011
    Material Weakness Repeat
  • 1123719 2024-012
    Significant Deficiency Repeat
  • 1123720 2024-012
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $10.89M
84.063 Federal Pell Grant Program $4.74M
11.028 Connecting Minority Communities Pilot Program $2.35M
84.031 Higher Education Institutional Aid $555,668
84.007 Federal Supplemental Educational Opportunity Grants $480,658
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $446,604
84.042 Trio Student Support Services $441,950
84.120 Minority Science and Engineering Improvement $427,368
84.033 Federal Work-Study Program $390,521
93.317 Emerging Infections Programs $363,742
84.217 Trio McNair Post-Baccalaureate Achievement $322,726
84.047 Trio Upward Bound $256,358
47.076 Stem Education (formerly Education and Human Resources) $137,979
15.932 Preservation of Historic Structures on the Campuses of Historically Black Colleges and Universities (hbcus). $63,530
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $51,145
93.310 Trans-Nih Research Support $48,409
45.313 Laura Bush 21st Century Librarian Program $40,928
12.598 Centers for Academic Excellence $32,974
97.062 Scientific Leadership Awards $27,918
84.335 Child Care Access Means Parents in School $23,238
17.268 H-1b Job Training Grants $20,962
97.061 Centers for Homeland Security $17,900
11.417 Sea Grant Support $14,474
54.001 Intelligence Community Centers for Academic Excellence $11,094
89.003 National Historical Publications and Records Grants $6,956
84.425 Education Stabilization Fund $4,647
93.859 Biomedical Research and Research Training $1,550